Catching Up on the New 401(k) Super Catch-Up Contributions Coming in 2025

This article is from The National Law Review: https://ow.ly/vQv150UsVMR Starting in 2025, the landscape for retirement plan contributions is about to shift—especially for older employees. Thanks to the SECURE 2.0 Act, workers ages 60 to 63 will be eligible to make “super-catch-up contributions” to their 401(k) plans, offering a valuable opportunity to boost retirement savings during the final years of their careers. But with this opportunity comes complexity. Employers will need to update plan documents, systems, and communications to ensure compliance and clarity. Here’s what you need to know.

What Are Super-Catch-Up Contributions?

Under current law, participants aged 50 and older can make catch-up contributions to their 401(k) plans—in 2025, this amount will be $7,500.

Beginning in 2025, however, participants aged 60 to 63 at any point during the tax year can contribute even more:

The greater of $10,000 or
150% of the regular catch-up limit (which means $11,250 in 2025, if the standard catch-up is $7,500)

Once a participant turns 64, they return to the standard catch-up contribution limit.

Age	Catch-Up Contribution Limit (2025)
50–59	$7,500
60–63	$10,000 or 150% of standard limit ($11,250)
64+	$7,500

Why This Matters

The super-catch-up provision is designed to help late-career workers maximize their retirement savings—particularly those who may have fallen behind earlier in their careers. However, the law creates a new layer of complexity for employers and plan administrators.

This change requires:

Tracking participant ages more precisely
Adjusting payroll systems for the new contribution thresholds
Clarifying plan language and elections
Communicating updates to eligible employees

Does Your Plan Need to Be Amended?

This is where it gets tricky. The SECURE 2.0 Act doesn’t clearly state whether the super-catch-up provision is mandatory or optional for plans that already allow catch-up contributions.

Two interpretations are emerging:

1. Mandatory by Default

Some legal experts interpret the change as automatic for plans that adopt catch-up limits by referencing Internal Revenue Code Section 414(v). If this is the case, plans must implement the super-catch-up unless they amend their documents by the end of 2024 to either:

Remove catch-up contributions entirely, or
Opt out of the super-catch-up increase for ages 60–63

2. Optional for Employers

Another interpretation sees the super-catch-up as optional, meaning plan sponsors could wait until the general SECURE 2.0 amendment deadline of 2026 to decide. But they’d still need to document the decision and adjust their administration and systems accordingly starting in 2025.

Until the IRS issues additional guidance, employers should prepare for either possibility and begin internal planning now.

Action Steps for Employers

To prepare for these upcoming changes, employers should:

Review plan documents and determine whether amendments are needed before the end of 2024.
Coordinate with payroll and recordkeeping providers to ensure systems can track and apply age-based limits.
Communicate clearly with employees about contribution options and eligibility.
Document decisions regarding whether to implement or delay the super-catch-up provision.
Stay alert for further IRS guidance, which may clarify whether these changes are mandatory or optional.

Final Thoughts

The 2025 super-catch-up provision under SECURE 2.0 is a promising opportunity for older workers—but it’s also a challenge for employers. With the year-end amendment deadline potentially looming, now is the time to assess your plan strategy and ensure you're ready to support employees while staying compliant.

If you need help reviewing your retirement plan documents or preparing for the implementation of SECURE 2.0 changes, our team is here to assist.